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A fundamental understanding of the consolidated return rules is critical for tax professionals who practice in the corporate tax area. This is particularly the case for those involved in mergers and acquisitions, as the consolidated return rules frequently change the otherwise applicable tax consequences of transactions. This year's program will provide participants with a strong foundation for understanding the primary consolidated return provisions that are frequently encountered in practice. Leading private practitioners in the field and government officials responsible for drafting the regulations will explain the fundamentals and key nuances of these rules.
What You Will Learn
- Get an introduction to basic consolidated return principles, including defining an affiliated group
- Learn to identify transactions affecting the continuation of a consolidated group
- Study the investment adjustment system – purposes and application
- Explore consolidated tax attributes, including the basics of consolidated Section 382 and separate return limitation year (“SRLY”) principles
- Analyze intercompany transactions, including TCJA issues
- Get an overview of consolidated return issues on the disposition of stock of members of a consolidated group, including an overview of the unified loss rules
Program Level – Overview
Intended Audience - Attorneys at law and accounting firms and in-house tax counsel seeking an introduction to the mechanics of the consolidated tax return regulations.
Prerequisites – An interest in exploring the basics of the consolidated tax return regulations.
Advanced Preparation – None